ML14212A401
| ML14212A401 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Indian Point  |
| Issue date: | 07/18/2014 |
| From: | Rheault C C & D Technologies |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML14212A401 (5) | |
Text
C.& NNO lBtV~I~ 1400 Union Meeting Road*EOINOWGIB Blue Bell, PA 19422Power Solutions Phone: (215) 619-2700Fax: (215) 619-7823July 18, 2014VIA FACSIMILENuclear Regulatory CommissionOperations Center301-816-5151VIA REGULAR MAILDocument Control DeskUS Nuclear Regulatory CommissionWashington, DC 20555-001VIA OVERNIGHT DELIVERYUS Nuclear Regulatory Commission11555 Rockville PikeRockville, MD 20852-2746
Subject:
Final Report -1 OCFR Part 21 Evaluation regarding cracking in KCR-13 Standby Battery JarsThe purpose of this letter is to provide the NRC a report in general conformity to the requirements of10CFR Part 21.21 (a)(2). On October 22, 2013 C&D Technologies, Inc. ("C&D") was informed by EntergyNuclear Northeast that a KCR-13 battery installed at the Indian Point Nuclear Energy Center (IPEC) haddeveloped a small crack in the polycarbonate jar material. The jar is a safety related component with theprimary function of containing electrolyte. The battery was removed from service and sent by IPEC toLucius Pitkin, Inc. (LPI) of New York, NY, for analysis.As C&D did not have access to the components of the allegedly defective battery, and a report had notyet been issued by Lucius Pitkin, C&D filed the requisite interim reports until receiving the analysis reportfrom LPI. This letter serves as C&D Technologies' final analysis of the issue. It should be noted that noadditional physical evaluation was performed by C&D and therefore this evaluation is based solely on thereport provided by LPI.The conclusions of the LPI report are as follows:1. The cracked jar and cover that required removal of the cell were not directly related to thedeformation of the post bushing from corrosion and did not appear to be a result of the radialstresses that the corrosion products would have created due to the volumetric increases.2. The crack initiation site occurred at the lip of the jar in an area of the jar cover seal, where theMMA adhesive is used.3. The crack surface showed indications of both environmental stress cracking (ESC) and fatiguefailure.4. Chemical analysis of materials near the crack initiation area did not reveal any trace of the stresscracking agent.ii35Vý Part 21 Evaluation IPEC crack in KCR-13 Battery JarJuly 18, 2014ConclusionsWhile the images do show indications of ESC and fatigue, the lack of chemical evidence of the actualagent makes it difficult to determine the source of the material. Polycarbonate (the container material) hasknown stress cracking agents for example esters, aliphatic hydrocarbons, aromatic hydrocarbons,halogenated hydrocarbons, ketones, etc. and the C&D Installation and Operation Manual clearly statesthat the only approved materials for contact with the jar and cover (other than materials used in theconstruction of the battery) for cleaning purposes is water and sodium bicarbonate (soda ash). If one ofthe previously mentioned materials came into contact with the jar, it could have caused the ESC that wasobserved.The standing recommendation to system operators is to limit any chemical that can come into contactwith the battery to only approved materials. In the event that an unapproved material contacts the battery,the unit should be cleaned and observed for any subsequent damage caused by the agent.Required information as per 1OCFR Part 21.21(d)(4) follows:(i) Name and Address of the individual or individuals informing the CommissionChristian Rheault (or Designee)President and Chief Executive OfficerC&D Technologies, Inc.1400 Union Meeting RoadBlue Bell, PA 19422-0858(ii) Identification of the facility, the activity, or the basic component supplied for such facilityor such activity within the United States which fails to comply or contains a defect.KCR-13 Batteries, manufactured in 2005, battery manufacturing date is on the label.(ill) Identification of the firm constructing the facility or supplying the basic component whichfails to comply or contains a defectC&D Technologies, Inc.1400 Union Meeting RoadBlue Bell, PA 19422-0858(iv) Nature of the defect or failure to comply and the safety hazard which is created or could becreated by such defect or failure to complyThe cracked jar which has been evaluated by an external lab does not indicate a potential defectwhich could create a substantial safety hazard(v) The date on which the information of such defect or failure to comply was obtainedOctober 22, 2013(vi) In the case of a basic component which contains a defect or fails to comply, the numberand location of these components in use at, supplied for, being supplied for, or may besupplied for, manufactured or being manufactured for one or more facilities or activitiessubject to the regulations in this Part.KCR-13 batteries used at Nuclear Plants in 1E applications made in 2005 Part 21 Evaluation IPEC crack in KCR-13 Battery JarJuly 18, 2014Qty ofutility Plant Name Battery Model BatteriesEntergy Indian Point KCR-13 NUC 72Xce[ Energy Monticello KCR-13 NUC 62(vii) The corrective action which has been, is being, or will be taken; the name of the individualor organization responsible for the action; and the length of time that has been or will betaken to complete the action.Co-Current Actions underway to complete the evaluation:a) None. Evaluation complete.(viii) Any advice related to the defect or failure to comply about the facility, activity, or basiccomponent that has been, is being, or will be given to purchasers or licensees.U.S. Licensees using batteries possibility containing the alleged defect have been notified of thefiling of this final report with recommendations that they examine their batteries for any signs ofproblems. See attached notification letter.(ix) In the case of an early site permit, the entities to whom an early site permit wastransferred.Not applicableIf you have any questions or wish to discuss this matter or this report, please contact:Robert MalleyVP Quality and Process Engineeringbmallevycdtechno.com(215) 619-7830Sincerely,Christian RheaultPresident and Chief Executive OfficerC&D Technologies, Inc.Attachment -C&D Letter to Users of KCR-13 batteries entitled "Final Report -KCR-13 Cracked Jar",dated 7/18/14Cc: D. AndersonJ. MillerR. MalleyS. DiMauroL. CarsonJ. Anderson Part 21 Evaluation IPEC crack in KCR-13 Battery JarJuly 18, 2014cTE H HNOLOGIES, INC. 1400 Union Meeting RoadPower S olUtion S Blue Bell, PA 19422Phone: (215) 775-1314Fax: (215) 619-7887July 18, 2014To: Entergy Operations, Inc.P.O. Box 31995Jackson, MS 39286-1995Attn: Manager, Operating Experience/CAAM-ECH-25Monticello Nuclear Generating Plant2807 W. County Road 75Monticello, MN 55362-9637Ref: Final Report- KCR-13 Cracked Jar
Dear Sir/Madam:
C&D Technologies, Inc. ("C&D") is filing a final report with the NRC for an incident that occurred with asafety related product at Indian Point Energy Center.As related in previous communications, on October 22, 2013 Entergy Nuclear Northeast informed C&Dthat a KCR-13 battery installed at the Indian Point Nuclear Energy Center had developed a small crack inthe polycarbonate jar material. The immediate response by Entergy was to replace the affected batterywith an on-site spare. This battery was not returned to C&D for analysis, but was rather sent by Entergyto Lucius Pitkin, Inc. (LPI), of New York, NY for analysis. Representatives from C&D and ESA ConsultingEngineers were present at Lucius Pitkin for the initial teardown of the affected battery. C&D has receivedand reviewed the report provided by LPI, and an evaluation has been performed by C&D engineering.LPI's report reached the following conclusions:1. The crack that developed in the jar was not related to cover radial stresses from the batteryterminal, and was not connected to any cover crack. It was initiated in the jar lip itself in thejar/cover seal area.2. The crack had evidence of both environmental stress cracking (ECS) and fatigue failure. ECS isa failure mechanism that requires an external chemical agent.3. Chemical analysis of the materials near the crack initiation point did not reveal any traces of thestress cracking agent. This is not unusual as most stress cracking agents for polycarbonate arevolatile materials that can evaporate with timeC&D Engineering reviewed the report and confirmed the indications of ECS and fatigue failure. As notedpreviously, the battery components were not available to C&D and the evaluation was based solely on theLPI report. With no evidence of the stress cracking agent remaining in the failure area no specificconclusions can be drawn as to the root cause of the crack.Based on the report and subsequent analysis the following recommendations are made for users of KCRproduct:1. Inspect battery cells for cracks in the clear polycarbonate jar material. Any batteries found withcracks should be replaced, and the cells returned to C&D for analysis. Requirements for visualinspection are described in the C&D 1&O manual for flooded products, available on the C&Dwebsite.
Part 21 Evaluation IPEC crack in KCR-13 Battery JarJuly 18, 20142. Review and enforce C&D recommendations for cleaning materials used on batteries. C&D's I/Omanual specifically limits neutralization and cleaning materials to sodium bicarbonate and water.Use of any solvent or commercial cleaning compounds to clean polycarbonate jars is strictlyprohibited.Field History: As related in previous communications, the incidence of this failure mode in KCRpolycarbonate jars is rare. C&D reviewed:* Warranty claims for all KCR products (nuclear safety related and commercial) dating back toJanuary 2000.* Customer complaints for all customers, since the database was established in 2009.* Sales records for nuclear safety related and for commercial KCR products since 1997No claims or complaints have been made for cracked jars in any nuclear safety related KCR productusing polycarbonate materials. Since 1997, C&D's sales records indicate 7,703 KCR cells of all sizes,and 1,373 KCR-13 cells have been produced for nuclear safety related applications. Approximately60,000 cells have been produced for non-safety related applications. Of these units two batteries havebeen reported to have cracks in the field. With the Indian Point incident included, the failure rate for jarcracking for KCR-13 is 0.013% for nuclear safety related product, and 0.004% for KCR's in allapplications.C&D Contacts: Further information on this issue can be obtained from:Larry Carson -Nuclear Product ManagerOffice Phone 215-775-1314Email: Icarson@cdtechno.comRobert Malley -VP Quality and Process EngineeringOffice Phone 215-619-7830Email bmalley@cdtechno.comBest Regards,Larry CarsonNuclear Product ManagerC&D Technologies, Inc.cc: C. Rheault -President and CEOD. Anderson -VP General CounselJ. Miller -VP OperationsR. Malley -VP Quality and Process EngineeringJ. Anderson -VP New Technology and Battery DesignL. Carson -Nuclear Product ManagerS. DiMauro -Quality Systems Manager